The Quality category of MIPS typically comprises 60% of a clinician’s or organization’s MIPS score. Factors such as the quality reporting method and measures you select have great bearing on the MIPS Quality score, level of clinician engagement, and administrative costs. We summarize here some key points covered in our June 2017 ABCs of MIPS webinar on decisions impacting the MIPS quality score.
Why should you revisit your 2016 and prior Medicare quality reporting decisions, such as for the legacy Physician Quality Reporting System (PQRS)? You’ll want to revisit your previous strategies because previous ways of approaching PQRS may not be optimal for MIPS. First, MIPS has changed quality from a pay-for-reporting program to a pay-for-performance program based upon a continuous scoring scale where every point translates into financial and reputational impact. Second, PQRS reporting methods and measures have changed under MIPS. For instance, the qualified-registry measures group reporting method (requiring only 20 patients to be reported) has been eliminated by CMS. Pitfalls of not revisiting your PQRS decisions include not checking for recent EHR vendor support for reporting methods or measures and underestimating the time and cost of data extraction. In particular, MIPS quality measure benchmarks are specific to reporting method and may result in low scores for previously-selected PQRS measures.
1. Selecting Reporting Method and Measures
There are no less than 8 different MIPS quality reporting methods, and selecting the reporting method is interrelated with selecting measures, as each method supports a restricted set of measures. It is common to iterate multiple times between selecting a method and selecting measures until multiple factors such as measure performance, clinician engagement, and EHR support are properly balanced.
One of the most impactful decisions is whether to report clinicians for MIPS individually or as a group defined by a common billing tax identification number (TIN). Selecting measures for each clinician versus selecting common measures for the entire TIN can result in large differences in MIPS scores and reimbursement. In addition, the administrative effort and cost of reporting can vary significantly.
Another key factor impacting quality scores is the structure of the percentile tiers of each measure’s benchmark. If a measure is “topped-out”, meaning that the national performance is very high (such as having average performance rates of 90%+ ), then it will be harder to achieve the full 10 out of 10 performance points for that measure. Or, if a measure does not have a benchmark, then the measure score will be pinned at only 3 out of 10 points. There are cases where the same clinical measure reported using two different methods have very different benchmarks, which in turn impacts method selection.
2. Deciding Which Clinicians to Report
On the surface, this is a seemingly simple decision: report those clinicians deemed by CMS to be individually-eligible for MIPS and do not report those who are not. However, there are subtleties. For instance, for group reporting, not including quality data associated with individually-excluded clinicians could violate data completeness requirements. Specifically, those clinicians individually-excluded from MIPS due to being first-year Medicare clinicians, having low Medicare volume, or sufficiently participating in advanced alternative payment models (AAPMs) may nevertheless need to include their quality data in a group submission for their TIN in order to meet data completeness requirements. In addition, organizations may want to report clinicians for MIPS who are ineligible for 2017, yet want to receive a CMS MIPS feedback report in Fall 2018 prior to those clinicians becoming eligible for MIPS in 2019 due to their professional credentials (e.g. physical therapists).
3. Identifying Where to Focus Quality Improvement Efforts
In light of how the MIPS score is impacted by a wide-ranging set of performance measures across multiple categories, it can be daunting to identify where to focus limited time and resources on improvement efforts to yield the maximum score increase. An important realization is that not all MIPS quality measures are created equal in terms of the impact of performance improvements on the MIPS score. As described above, an example is that topped-out measures may yield only small score increases for a given increase in performance rates as opposed to those resulting from other measures. It can be very helpful to apply analytical methods to rank the measures by the amount of “leverage” each has on further increases in the MIPS quality score. Efforts can then be focused on those measures with the highest leverage. Measure leverage can be impacted by measure benchmarks, current measure performance, and time left in the performance year. Additional factors to consider when identifying “low-hanging fruit” is clinicians’ varying abilities or desire to change workflows and behaviors, as well as what type of change must be instituted to effect improvement.
The Key Takeaway
The major takeaway from our June 2017 webinar is that MIPS quality optimization decisions are interrelated with each other and differ compared to pre-MIPS. Therefore, it is important to revisit those decisions made previously for legacy PQRS and start monitoring clinician MIPS scores while there is still enough time left in the year to gain meaningful improvements.
Tom S. Lee
Founder and CEO
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